MAS amends MLA and LCR requirements for predominantly-banking financial holding companies (Notice FHC-N649), effective 1 September 2026

Predominantly-banking financial holding companies in Singapore must meet amended MLA/LCR requirements and adopt the revised Form 2 from 1 September 2026

Change
On 28 May 2026, MAS issued Notice FHC-N649 (Amendment) 2026, revising the Minimum Liquid Assets (MLA) and Liquidity Coverage Ratio (LCR) requirements for predominantly-banking designated financial holding companies with a Singapore bank subsidiary, together with an amended Form 2 reporting form, effective 1 September 2026.
Why it matters
The amendment revises the MLA and LCR requirements that predominantly-banking designated financial holding companies with a Singapore bank subsidiary must meet under Notice FHC-N649, issued under the Financial Holding Companies Act 2013. It also amends Form 2 (LCR, MLA, cashflows and available unencumbered liquid assets), so affected FHCs must report on the revised form from the effective date; Form 1 is unchanged. The amendment is dated 28 May 2026 and takes effect on 1 September 2026, and forms part of a coordinated MAS update to the liquidity-requirement notices issued the same day for banks (Notice 649) and merchant banks (Notice 1015) — so holding-company-level liquidity compliance moves in step with the entity-level bank requirements.
Implications
  • Predominantly-banking designated financial holding companies with a Singapore bank subsidiary must implement the amended MLA/LCR requirements under Notice FHC-N649 by 1 September 2026, on which the prior requirements cease to apply — and must align holding-company/group-level liquidity compliance with the entity-level Notice 649 bank amendment that takes effect the same day.
  • Liquidity-risk and regulatory-reporting teams at affected FHCs must adopt the revised Form 2 (LCR, MLA, cashflows and available unencumbered liquid assets) for reporting from 1 September 2026 — submissions on the superseded Form 2 after that date are non-compliant; Form 1 is unchanged and continues to apply.

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